6-25-CV-01159-MC

📧 from White "we are not conceding the relvancy"

Hi Logan,

Our production of an email referencing a prior situation does not mean we are conceding the relevancy of the prior information. I have no information suggesting the alleged December 10, 2024 “threat assessment” had anything to do with the later restrictions on your visiting Representative Boshart Davis’s office or the Capitol. Moreover, LAC’s production of documents is separate from OSP’s.

Absent some reason to believe the December 10, 2024, situation is relevant to the remaining issues in dispute in this lawsuit, we do not intend to gather and produce related documents.

📧 to White "Two points, briefly"

Tracy, Thank you for the response. Two points, briefly. First, on the "not part of the operative complaint" objection: LAC has already produced ISAAC-LAC-SDT-000249, a document from this same date and subject matter, without maintaining a relevance objection against it. I'm not asking

📧 from White "We are not planning to produce"

Hi Logan, We are not planning to produce those. The Court has limited the case to the two Capitol restrictions occurring in January and February 2025. There is no indication this “threat assessment” bears on those.

📧 to White "we have conferred"

Tracy, To be precise: I have not expressed a feeling. Fed. R. Civ. P. 33(b)(1)(A), 34(b)(2)(A), and 36(a)(3) places the response obligation on "the party to whom the request is directed." I'd ask that my position be addressed

📧 from White "sorry you feel that way"

I’m sorry you feel that way. I will file a motion for an extension. I will state we’ve conferred unless you think we should discuss more? At 1445 Actually, I will be emailing the Court Deputy, as you previously did, to see if a formal motion is necessary.

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📧 to White "Two points, briefly"

📧 from White "We are not planning to produce"

📧 to White "we have conferred"

📧 from White "sorry you feel that way"